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Patna High Court

Satyam Kumar @ Satyam Kumar MandalversusThe State of Bihar

Decided
Disposal
ALLOWED

Holding

The Court granted bail to the petitioner, directing him to furnish a bail bond of Rs.10,000 with two sureties.

Summary

The petitioner, Satyam Kumar, was arrested in connection with the death of his wife, who was allegedly killed by hanging following a dowry dispute. The prosecution alleged that the petitioner and his family hanged the deceased, while the defence argued that the death was a suicide, supported by the post‑mortem report showing asphyxia due to hanging and an independent witness statement. The petitioner, who has no prior criminal record, applied for bail under Sections 80(2) and 3(5) of the B.N.S., 2023. The State opposed bail, emphasizing the dowry demand and the short interval between marriage and death. After hearing both sides, the Court found the evidence insufficient to deny bail and ordered the petitioner to be released on a bail bond of Rs.10,000 with two sureties. The bail order was issued by Justice Ashok Kumar Pandey.

Issues considered

  • Whether bail should be granted to the accused under Sections 80(2) and 3(5) of the B.N.S., 2023 in a case of alleged dowry‑related homicide.
  • Whether the circumstances of the death indicate murder or suicide, and how that impacts bail considerations.

Legislation cited

Subjects

  • bail
  • dowry death
  • murder
  • suicide
  • criminal procedure
  • Section 80
  • Section 3
  • Section 108
  • dowry harassment

Judgment

                      IN THE HIGH COURT OF JUDICATURE AT PATNA
                              CRIMINAL MISCELLANEOUS No.76219 of 2025
                          Arising Out of PS. Case No.-119 Year-2025 Thana- SIKTI District- Araria
                 ======================================================
                 Satyam Kumar @ Satyam Kumar Mandal S/O Sanjay Mandal R/O Vill.- Tira
                 Khardah, Ward no. 4, P.S.- Sikty, Dist.- Araria.

                                                                                      ... ... Petitioner/s
                                                         Versus
                 The State of Bihar

                                                        ... ... Opposite Party/s
                 ======================================================
                 Appearance :
                 For the Petitioner/s     :         Mr. Ramesh Kumar Singh, Advocate
                 For the Opposite Party/s :         Mr. Akshay Lal Pandit, APP
                 ======================================================
                 CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
                                       ORAL ORDER

3   13-01-2026                     Heard Mr. Ramesh Kumar Singh, learned counsel

                   for the petitioner and Mr. Akshay Lal Pandit, learned APP for

                   the State.

                                2. The petitioner has prayed for bail in connection

                   with Sikty P.S. Case No. 119 of 2025 registered for the offence

                   punishable under Sections 80(2), 3(5) of the B.N.S., 2023.

                                3. The case of the prosecution in short is that the

                   daughter of the informant was married to the petitioner on

                   06.02.2025. It is further alleged that she was subjected to cruelty

                   by the in-laws due to non-fulfillment of the dowry demand of

                   Rs. 5,00,000/-. The informant came to know from the villagers

                   that his daughter has been killed. The informant has alleged that

                   the petitioner, along with his family members, has hanged the

                   deceased.
Patna High Court CR. MISC. No.76219 of 2025(3) dt.13-01-2026
                                            2/3




                       4. Learned counsel appearing on behalf of the

          petitioner has submitted that petitioner is innocent and has

          committed no offence. He has been falsely implicated in this

          case. Learned counsel for the petitioner submits that from the

          perusal of the postmortem report, it will transpire that the team

          of doctors conducting the autopsy of the deceased has opined

          that the cause of death is due to asphyxia as a result of hanging

          and only one antemortem injury, i.e., a single blackish-brown

          ligature mark over the thyroid cartilage from the left mastoid

          region to the right mastoid region, approximately 1 cm wide. He

          also submits that this goes to show that it is a case of hanging. It

          has further been submitted that the deceased has committed

          suicide, and after the investigation, the police have submitted a

          chargesheet under Section 108 of the BNS. He further submits

          that during the course of investigation, the independent

          witnesses have stated that the deceased and the petitioner was

          smoking a cigarette; thereupon, hot talk took place between

          them. The deceased went in the house and hanged herself. When

          the witnesses went there, they found the door was bolted from

          inside and the deceased was hanging there. This statement is

          there in paragraphs 64 and 66 of the case diary. He further

          submits that a statement has been made in para 3 of the petition
           Patna High Court CR. MISC. No.76219 of 2025(3) dt.13-01-2026
                                                       3/3




                     that petitioner has no criminal antecedent and he is languishing

                     in judicial custody since 11.08.2025.

                                  5. The application for bail is opposed by learned APP

                     for the State and the learned counsel for the informant and

                     submits that the deceased was married on 06.02.2025 and the

                     death was caused within six months of the marriage. It has

                     further been submitted that there was demand of Rs. Five lakhs

                     as dowry.

                                  6. Having heard learned counsel for the parties and

                     considering the facts and circumstances of the case, this Court is

                     inclined to enlarge the petitioner on bail. The above named

                     petitioner is directed to be enlarged on bail on furnishing bail

                     bond of Rs. 10,000/- (Rs. ten thousand only) with two sureties

                     of the like amount each to the satisfaction of the learned Judicial

                     Magistrate, 1st Class, Araria in connection with Sikty P.S. Case

                     No. 119 of 2025.



                                                    (Ashok Kumar Pandey, J)
Sudhanshu/-

U      T


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